Interpretation ID: aiam2848
Assistant General Manager
Nippondenso Company
Ltd.
16 Henderson Drive
W. Caldwell
NJ 07006;
Dear Ms. Racanelli: This is in reply to your letter of August 10, 1978, to Mr. Vinson o this office requesting confirmation of interpretations of Paragraph S4.7 of Motor Vehicle Safety Standard No. 108.; This confirms your interpretations. Paragraph S2, *Application* states the coverage of the standard: t specified vehicle types 'and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies' i.e. those vehicles manufactured on or after January 1, 1972. The equipment items listed in Tables I and III are required motor vehicle lighting equipment, and any item manufactured as a replacement for one of these items that has been original equipment on 1972 or later model vehicles, must meet Standard No. 108's requirements and be so certified.; Paragraph S4.7 allows certification by means of a DOT symbol placed o the item itself. No specific design or size is required. The manufacturer may certify by other means as well, specifically those set forth for all equipment items covered by a standard, in Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403): 'a label or tag on [the] item or on the outside of a container in which such item is delivered'. We would view an indelible stamp on the container as 'a label' within the meaning of Section 114 if Nippondenso wished to certify by this means.; I have no other suggestions regarding use of the DOT symbol, excep that it should be of a size and in a location sufficient to readily identify the item as meeting Federal requirements, thereby avoiding any possible misunderstanding.; Sincerely, Joseph J. Levin, Jr., Chief Counsel